The transport and logistics sector represents a major economic pillar, generating complex and specific tax issues. Companies in this field face particular regulatory challenges, requiring in-depth expertise to effectively navigate the French and international tax landscape. Our firm, which specializes in specialized industries, can help you optimize your transport and logistics tax situation.

What is transport and logistics?

Transport and logistics encompass all activities related to the movement, storage and distribution of goods and people. This strategic sector represents a considerable economic weight in France, with annual sales exceeding 240 billion euros and employing more than 1.4 million people, i.e. around 5% of the national GDP. It includes road, rail, sea and air transport, as well as logistics, warehousing and distribution services, all sectors undergoing rapid digital transformation with the rise of e-commerce and delivery platforms.

Transport and logistics companies operate within a particularly complex regulatory framework, distinguished from other business sectors by its operational and territorial specificities. They face multiple and evolving tax obligations: differentiated VAT regimes depending on the nature and destination of services, sector-specific taxes such as the TICPE, special depreciation rules for vehicle fleets, and new tax issues linked to the digitalization of services (collaborative economy, last-mile delivery, digital platforms).

Specific tax aspects of the transport and logistics sector

The transport sector benefits from special tax regimes, adapted to the operational constraints of the business. In particular, shipping companies can opt for the tonnage tax, a flat-rate taxation system based on transport capacity rather than actual profits. This regime is available to companies operating vessels of at least 1,000 gross tons, subject to a ten-year commitment and compliance with strict conditions governing strategic and commercial management from France.

Road hauliers also benefit from specific tax advantages, notably in terms of expense deductions and vehicle depreciation. Declining-balance depreciation can be applied to transport vehicles, with a coefficient of 1.25 for commercial vehicles, enabling accelerated tax deductions. Companies investing in clean vehicles (electric, hybrid or NGV) benefit from a 40% bonus on the purchase price, reinforcing the attractiveness of the energy transition.

Fuel taxation is a major issue for transport companies. Commercial road hauliers benefit from a partial TICPE refund of 5.35 centimes per liter for commercial diesel, subject to a minimum volume of 7,500 liters per year. For public road passenger transport, this reimbursement amounts to 18.77 centimes per liter. These support measures are designed to maintain the sector’s competitiveness in the face of growing regulatory constraints.

VAT and territoriality in transport

VAT in the transport sector presents particular complexities linked to the international nature of operations. The rules governing the territoriality of supplies of services apply differently depending on the type of transport and the destination. Freight transport is generally subject to the standard rate of VAT (20% in France), while passenger transport benefits from the reduced rate of 10%. For example, a French company transporting goods by road to Germany will charge French VAT, while international shipping may be exempt.

The intra-Community transport of goods is VAT-exempt, subject to compliance with specific conditions: obtaining a valid intra-Community VAT number from the consignee, justification of the physical exit of the goods from French territory by a transport document (CMR, bill of lading), and timely declaration. Companies must keep these documents for 6 years, and declare these operations via the Déclaration d’Échanges de Biens (DEB) when the threshold of €460,000 in annual shipments is exceeded.

Logistics and warehousing services are subject to specific territoriality rules, particularly when provided to customers in other EU member states. These services are generally taxable at the place where they are physically performed. Companies must also keep a European Services Declaration (ESD) for services rendered to taxable persons in other member states, with a declaration threshold of €100,000 per year. Passenger transport has its own specific features, with exemption rules for international transport over 100 km.

Tax optimization for transport companies

Tax optimization in the transport and logistics sector requires a global approach, taking into account the specificities of the sector and the company’s objectives. Optimization strategies can focus on legal structuring, choice of tax regimes, investment planning and optimizing the location of operational activities.

The transfer of a transport company can benefit from the Pacte Dutreil scheme, which offers a 75% reduction in transfer duties. Subject to a minimum 4-year holding period, this mechanism is particularly advantageous for family businesses in the sector. For a transport company valued at 2 million euros, the savings can amount to 300,000 euros on inheritance tax.

Depending on the type of equipment and its environmental impact, investments in transport equipment may be subject to accelerated depreciation or depreciation allowances. The “suramortissement écologique” scheme allows an additional deduction of 40% for electric or rechargeable hybrid light commercial vehicles, subject to a minimum holding period of 2 years.

For transport and logistics groups, optimization often requires appropriate legal structuring, notably through the creation of holding companies or tax consolidation arrangements. These arrangements enable results to be pooled and the group’s overall tax burden to be optimized, while complying with anti-abuse rules.

Strategic business location is also a major optimization lever. Companies can take advantage of urban tax-free zones, specific territorial schemes or optimize their intra-group flows in line with international tax treaties, particularly relevant for international transport activities.

Transfer pricing and international logistics groups

Multinational groups in the transport and logistics sector must comply with transfer pricing regulations. This obligation applies to transactions between related entities, including the provision of logistics services, brand royalties and cost-sharing agreements.

Transfer pricing documentation must demonstrate that the conditions applied between related entities correspond to those that would be agreed between independent companies. This requires an in-depth economic analysis of the functions, assets and risks of each entity.

Tax authorities pay particular attention to the structures used to centralize logistics activities, especially when they are located in privileged tax jurisdictions.

Legal expertise and customized support

The tax complexity of the transport and logistics sector calls for specialized legal support. Our firm is involved at every stage of a company’s life, from start-up to transfer, including external growth and restructuring.

We assist our customers in their dealings with the tax authorities, whether in the context of tax audits, rescripts or litigation. Our sector expertise enables us to anticipate risks and propose solutions tailored to the specific challenges of transport and logistics.

Constantly changing tax regulations, particularly in the environmental and digital fields, require constant legal monitoring. We support our customers in adapting their practices to new regulatory obligations.

Ecological transition and tax incentives

In response to environmental challenges, the transport and logistics sector is undergoing a far-reaching transformation of its tax system. The French government has introduced a number of tax incentives for clean and electric vehicles, designed to accelerate fleet renewal towards less polluting solutions. These measures include partial exemptions from company vehicle tax (TVS) and advantageous depreciation rates.

The “suramortissement écologique” is a major fiscal lever for companies in the sector. This mechanism allows tax deductions of up to 140% of the acquisition cost of certain low-emission vehicles, significantly improving the return on investment of green fleets. This measure is part of a global strategy to encourage responsible investment.

The ecological bonus and malus systems have a direct impact on the taxation of transport fleets. Companies must now integrate these parameters into their vehicle acquisition and renewal strategies. The malus, which can amount to several thousand euros for the most polluting vehicles, represents a significant tax burden that operators are seeking to avoid by switching to alternative powertrains.

The gradual introduction of Low Emission Zones (ZFE) in major French conurbations also has significant tax implications. Transport and logistics companies must anticipate these regulatory constraints by adapting their fleets, which may entitle them to specific tax benefits such as exceptional depreciation or ecological transition tax credits.

To support this transformation, a tax credit for the installation of electric charging stations has been introduced. This scheme enables companies to deduct a significant proportion of the cost of installing recharging infrastructure on their logistics sites or in their fleets. This measure is particularly strategic for last-mile logistics operators, faced with increasing traffic restrictions in urban areas.

• Strategic advantage: Companies that anticipate these transitions benefit not only from tax advantages, but also from a favorable commercial positioning with principals who are sensitive to CSR issues.
• Tax planning: By staggering green investments, you can optimize the impact of tax measures over several years.
• Regulatory watch: The evolving nature of these incentives calls for rigorous monitoring to maximize tax opportunities.